Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Detention of imported goods without complying with statutory requirements for seizure and notice is arbitrary and without legal authority. Even where goods may be prohibited, customs authorities retain discretion to allow provisional release on suitable conditions. Imported betel nut products retained pending classification assessment were directed to be released upon an indemnity bond for their value and a bank guarantee for part of the differential duty, subject to confirmation of fitness for human consumption. Customs authorities may continue adjudication in accordance with law. Demurrage waiver remains for consideration by the appropriate authority upon representation.
Detention of imported goods without complying with statutory requirements for seizure and notice is arbitrary and without legal authority. Even where goods may be prohibited, customs authorities retain discretion to allow provisional release on suitable conditions. Imported betel nut products retained pending classification assessment were directed to be released upon an indemnity bond for their value and a bank guarantee for part of the differential duty, subject to confirmation of fitness for human consumption. Customs authorities may continue adjudication in accordance with law. Demurrage waiver remains for consideration by the appropriate authority upon representation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4929 
